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FPA Member Code of Practice

CODE OF PRACTICE TO WHICH ALL FULL AND ASSOCIATE MEMBERS AGREE TO ABIDE AS A CONDITION OF MEMBERSHIP

All members of the Foodservice Packaging Association agree to abide by the FPA Code of Practice.

To operate their businesses in accordance with the laws, rules and regulations operating within the UK and EU within the markets in which they operate.

In the making of claims for products for sale within the EU, to quote evidence of receipt of any applicable EU certifications, standards and other approvals if required to make such a claim within the EU and be able to provide these upon request.

All products sold or produced for sale within the EU to be fully compliant with EU legislation and the legislation of individual EU member nations where sold. Copies of accreditation to be provided upon request.

To ensure their business takes all steps required to prevent an adverse impact upon the environment and that good environmental practices within their business are encouraged.

Not to discuss at any FPA event any item that might be construed as in breach neither of EU competition law nor to collude with other members in a way that breaches EU competition regulations. The terms of FPA Governance are detailed below and apply to all members.

To ensure all public statements made by and on behalf of the Member are decent, honest and truthful to the best of your knowledge, understanding and belief.

To support the global set of principles for corporate social responsibility set out in the Global Compact (appended), this includes operating fair employment practices.

To apply the highest ethical trading standards and never knowingly operate a business in such a way as to bring the foodservice packaging industry into disrepute.

In the event a member is alleged to be in breach of this code the member shall be notified in writing by the Executive Director. The member will be given 6 weeks in which to refute the allegation and to satisfy the Executive Committee of the Foodservice Packaging Association that they are fully compliant with the Code.

In the event such compliance is not received nor allegation rebutted by the due date the allegation will be discussed in confidence by the Committee of the Foodservice Packaging Association.

The member will be notified in writing of the outcome.

The member shall be afforded the right to appeal in person provided this request is made within 7 days of receipt of the outcome. The appeal shall be heard by a panel independent of the FPA.

The final decision made by the Appeal Committee is binding.

In the event a Member has been proven to be in breach of this Code the following will apply:

The Member’s Membership will immediately cancelled

There will be no rebate of any unused membership fee

The Member will not be permitted to attend any Foodservice Packaging Association function ad a guest of another Member. Any tickets for events purchased will be cancelled however there will be no rebate made for such tickets cancelled

The member will be required to remove the FPA logo from their web site, marketing, products, display and print.

FOODSERVICE PACKAGING ASSOCIATION GOVERNANCE: COMPETITION RULES

Industry associations exist primarily to defend common interests, promote better knowledge and expertise, and exchange non-competitive information. This is the case for the Foodservice Packaging Association. To ensure that the Foodservice Packaging Association does not unintentionally compromise its long-standing tradition of good governance, the following guidelines (based on The European Chemistry Council’s (CEFIC) publicly available governance and compliance policy) apply to members when attending FPA events and meetings. They are . Members may wish to consult a legal expert.

Members shall encourage fair competition. Members will compete fairly in all the markets they serve. They will not enter into illegal arrangements nor engage in illegal concerted activities with their competitors or with others. Products will be described truthfully and accurately. Misleading stakeholders through deceptive acts or practice, false advertising or claims, misinterpretation of other members’ products or other unfair methods of competition are in conflict with this Code of Practice.

Guidelines for FPA meetings and Events

Oversight/supervision: A Foodservice Packaging Association representative should be present at meetings and events. Discussions should be limited to agenda topics. Attendees should be provided with a copy of this note and an extra copy should be available for reference at all meetings.

Members should not, in fact or appearance, discuss or exchange information not in conformity with competition law including:

Market procedures: Company bids on contracts for particular products; company procedures for responding to bid invitations. Matters relating to actual or potential individual suppliers or customers that might have the effect of excluding them from any market or influencing the business conduct of firms toward them, etc.. Blacklist or boycott customers or suppliers.

Vigilance: Members and staff should protest against discussions or meetings which appear to violate the requirements set out here and these discussions or meetings should be suspended. You should disassociate yourself from any such discussions or meetings and leave meetings where offending discussions continue.

Prohibited discussion topics apply equally to social events including the Annual Awards Dinner and Exhibition, Golf and Activities’ Day and House of Commons Lunch (meetings for which terms and conditions apply). The list above is not exhaustive. It is intended for FPA staff and Member representatives who are responsible for managing meetings. It is also intended to be read and followed by attendees of meetings. These rules do not relieve individuals of their responsibility to use their own judgement in appropriate situations.

YOU AND YOUR COLLEAGUES AND GUESTS ARE REQUESTED TO SIGN IN TO ALL MEETINGS. THE PARAGRAPH BELOW IS SHOWN ON THE SIGN IN SHEET AND YOUR SIGNATURE CONFIRMS YOUR AGREEMENT TO ITS TERMS AS A CONDITION OF ATTENDING THE MEETING

In order to comply with competition law and to promote fair competition, Foodservice Packaging Association members while attending this meeting confirm that no discussions or exchanges of information will take place on competitively sensitive issues such as prices paid for or charged for products or services, production, transportation rates, market procedures or future plans with respect to these issues. This agreement applies to both the formal meeting and to the informal gatherings surrounding it. Please note the above list is not exhaustive. Your signature above confirms your agreement to the above terms as well as abiding by the FPA Code of Practice as a condition of attending this meeting / event.

WHERE IT IS NOT PRACTICALLY POSSIBLE TO SIGN IN TO EVENTS SUCH AS THE AWARDS AND HOUSE OF COMMONS LUNCH THEN THE ABOVE PARAGRAPH IS DEEMED TO APPLY TO ALL MEMBERS AND THEIR GUESTS WHO ARE ATTENDING AND ADHERENCE TO ITS TERMS IS A CONDITION OF SALE FOR EVERY EVENT. THE PURCHASE OF ALL TICKETS IS SUBJECT TO FPA TERMS AND CONDITIONS OF WHICH THE ABOVE IS A PART

THE UNITED NATIONS GLOBAL COMPACT

The Ten Principles

The UN Global Compact’s ten principles in the areas of human rights, labour the environment and ant-corruption enjoy universal consensus and are derived from:

The Universal Declaration of Human Rights

The International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work

The Rio Declaration on Environment and Development

The United Nations Convention Against Corruption

The UN Global Compact asks companies to embrace, support and enact, within their sphere of influence, a set of core values in the areas of human rights, labour standards, the environment and anti-corruption:

Human Rights

Principle 1: Businesses should support and respect the protection internationally proclaimed human rights; and

Principle 2: make sure that they are not complicit in human rights abuses.

Labour

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labour;

Principle 5: the effective abolition of child labour; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges;